Carswell v. Ferrari

CourtDistrict Court, D. Idaho
DecidedJune 20, 2025
Docket1:23-cv-00468
StatusUnknown

This text of Carswell v. Ferrari (Carswell v. Ferrari) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Carswell v. Ferrari, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF IDAHO

JACK CHRISTOPHER CARSWELL, Case No. 1:23-cv-00468-BLW-REP

Plaintiff,

vs. REPORT AND RECOMMENDATION

KYLE FERRARI,

Defendant.

Pending before the Court is Plaintiff’s Motion to Amend Pleadings and Join Parties (Dkt. 38). For the reasons set forth below, the undersigned recommends that the Court deny Plaintiff’s motion as currently submitted. The undersigned, however, invites Plaintiff to file objections to this Report and Recommendation if he believes he can remedy any of the factual defects outlined below. BACKGROUND Plaintiff filed this civil rights lawsuit on October 19, 2023. (Dkt. 1.) The Court dismissed Plaintiff’s first three complaints because they lacked sufficient factual matter to state a claim for relief. (Dkts. 4, 7, 10.) On May 22, 2024, Plaintiff submitted a Third Amended Complaint for the Court’s review. (Dkt. 11.) This complaint provided more context for Plaintiff’s claims, explaining that a Nampa police officer – Kyle Ferrari – signed a probable cause affidavit in October 2023 charging Plaintiff with committing misdemeanor crimes of disturbing the peace for yelling “fuck the police” at a neighbor on three different occasions. (Dkt. 11-1, Exh. 1.) Three months after the probable cause affidavit was signed, a Canyon County Clerk of Court issued a criminal summons ordering Plaintiff to appear in court on the charges. (Dkt. 11- 1, Exh. 2.) The summons was returned “non-found” by a Nampa police officer the same day.

Id. On March 7, 2024, Judge Debra Orr signed a warrant for Plaintiff’s arrest. (Dkt. 11-1, Exh. 3.) Nampa police Officer Bobby Maddox executed the warrant on March 27, 2024. Id. In the Third Amended Complaint, Plaintiff attempted to assert civil rights claims against eight Nampa police officers, including Officer Ferrari. According to Plaintiff, these officers (i) retaliated against him for exercising his free speech rights, (ii) failed to serve a summons on him prior to his arrest, (iii) improperly took him to jail upon his arrest instead of immediately presenting him to a magistrate judge, (iv) used excessive force against him, and (v) otherwise arrested him unlawfully. (Dkt. 11-1.) In October 2024, the Court conducted a detailed review of Plaintiff’s Third Amended

Complaint. (Dkt. 12.) Based on this review, the Court concluded that Plaintiff had presented sufficient facts to support a First Amendment retaliation claim against Officer Ferrari. The Court, however, found that Plaintiff’s remaining claims were either factually unsupported or legally flawed, and the Court dismissed every other claim without prejudice. Id. at 5. For example, the Court dismissed Plaintiff’s excessive force claim because Plaintiff had failed to present any factual allegations in support of this claim. Id. at 8-9. The Court also noted that Plaintiff’s Third Amended Complaint contained no allegations against several of the named officers and dismissed the claims against these officers. Id. at 9-10. The Court informed Plaintiff that it would not entertain a motion to reinstate any of these claims or add any new defendants until Defendant Ferrari was served and had appeared in the lawsuit. (Dkt. 12.) On November 8, 2024, Defendant Ferrari made his appearance in this lawsuit. (Dkt. 16.) The Court subsequently issued a scheduling order setting a deadline of April 10, 2025 for

Plaintiff to move to amend his pleading or join parties. (Dkt. 34.) On April 15, 2025, Plaintiff timely1 filed a motion to amend seeking to reinstate several previously dismissed claims and add claims against multiple new Defendants. (Dkt. 38.) The motion to amend does not present any new information about Plaintiff’s interactions with the Nampa police department or the details of his subsequent arrest and prosecution. LEGAL STANDARD The Court is required to screen complaints brought by litigants who proceed in forma pauperis. See 28 U.S.C. § 1915(e)(2). The Court must dismiss a plaintiff’s complaint, or any portion thereof, if it is (1) frivolous or malicious; (2) fails to state a claim upon which relief can

be granted; or (3) seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915(e)(2)(B)(i)-(iii). When evaluating whether a complaint states a claim upon which relief can be granted under § 1915(e)(2)(B)(ii), the court accepts as true all well-pleaded factual allegations in the complaint, disregarding any unsupported legal conclusions. Ashcroft v. Iqbal, 556 U.S. 662, 678

1 On April 7, 2025, Plaintiff emailed a copy of his motion to amend to defense counsel and the Court. Plaintiff mailed the motion to the Clerk’s Office the following day for filing. While the motion did not arrive at the courthouse until April 15, 2025, Plaintiff remained in contact with the Court and opposing counsel during this period, and the undersigned’s staff attorney promised that motion would be treated as timely filed. (2009).2 Next, having identified the adequately pleaded facts, the court “determine[s] whether they plausibly give rise to an entitlement to relief.” Id. at 679. Stated concisely, “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Id. at 678. Dismissal under this standard can be predicated on either (a) “a lack of cognizable legal theory” or (b) “the absence of sufficient facts

alleged under a cognizable legal theory.” Johnson v. Riverside Healthcare Sys., LP, 534 F.3d 1116, 1122 (9th Cir. 2008). Where, as here, a motion to amend suffers from factual deficiencies, a plaintiff should generally be notified of the defects and provided an opportunity to cure them. Jackson v. Carey, 353 F.3d 750, 758 (9th Cir. 2003) (prior to the amendment deadline, “dismissal without leave to amend is improper unless it is clear that the complaint could not be saved by any amendment”); see also Fed. R. Civ. P. 15(a) (prior to trial, “[t]he court should freely give leave” to amend a complaint “when justice so requires”). DISCUSSION

The undersigned construes the motion to amend as an attempt to reinstate the following claims, which the Court previously dismissed without prejudice: (i) a due process claim alleging that the Nampa Police Department improperly failed to serve Plaintiff with a summons before arresting him, (ii) an excessive force claim, (iii) an unlawful arrest claim against Officer Bobby Maddox for executing the state court arrest warrant, and (iv) unspecified civil rights claims

2 “The standard for determining whether a plaintiff has failed to state a claim upon which relief can be granted under § 1915(e)(2)(B)(ii) is the same as the Federal Rule of Civil Procedure 12(b)(6) standard for failure to state a claim.” Watison v. Carter, 668 F.3d 1108, 1112 (9th Cir. 2012). against Nampa police officers Justin Giesige, Rodger Holscher, “Officer Shepard,” James Williams, and Erick Moore.

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